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Our Comments As stated in paragraph 3 of Interpretation Bulletin IT-110R2 (Special Release), "A gift, for purposes of sections 110.1 and 118.1 of the Act, is a voluntary transfer of property without valuable consideration". ...

Its application extends to provisions such as the definition of a "Private Corporation" at paragraph 89(1)(f), the inadequate consideration rules at subsections 69(6) and (7) and other law where de facto control tests are not considered appropriate. ...

Paragraph 4 of IT-491 sets out some factors that may be taken into consideration when determining the main or chief use of a property.  ...

The level of reserves required by provincial legislation would also be an important consideration. ...

Whether or not a particular legal defeasance is a legal defeasance which effects novation can only be determined following consideration of all of the terms and conditions pertaining to the particular defeasance.  ...

You have offered two interpretations of CEE for our consideration: 1.      ...

Should you have a factual situation involving an actual taxpayer that you wish to have considered, you should forward all relevant facts and documentation to the appropriate district taxation office for their consideration. ...

Meeting with Finance In response to numerous queries received from Revenue Canada concerning the proposed Part 1.3 tax; Finance agreed to attend a meeting with us to discuss their intent and policy considerations inherent in the drafting of the Part 1.3 legislation. ...

., Compagny Law considerations relating to Corporate Actions and Reorganization, 1976 Conference Report, p. 235.]       ...

You have offered two interpretations of CEE for our consideration: 1. ...